Risk assessment of short-term intake of pyrrolizidine alkaloids in food: derivation of an acute reference dose

Pyrrolizidine alkaloids (PA) are phytochemicals that are known to act as human hepatotoxins and are also considered to be genotoxic carcinogens. Several plant-derived foods are frequently contaminated with PA, like teas and herbal infusions, spices and herbs or certain food supplements. With respect to the chronic toxicity of PA, the carcinogenic potential of PA is generally regarded as the critical toxicological effect. The risk assessment of the short-term toxicity of PA, however, is internationally less consistent. The characteristic pathological syndrome of acute PA toxicity is hepatic veno-occlusive disease. High PA exposure levels may lead to liver failure and even death as documented by several case reports. In the present report, we suggest a risk assessment approach for the derivation of an acute reference dose (ARfD) for PA of 1 µg/kg body weight per day based on a sub-acute animal toxicity study in rats after oral PA administration. The derived ARfD value is further supported by several case reports describing acute human poisoning following accidental PA intake. The here derived ARfD value may be used for PA risk assessment in cases where the short-term toxicity of PA is of interest in addition to the assessment of the long-term risks.

Factors affecting the quantitative uncertainty of the estimated short-term intake. Part I-Calculation methods

The calculation of the combined uncertainty of the international estimated short-term intake (IESTI) of ethephon residues in apples is shown as an example. The ethephon residues in apples were reported by the Joint FAO (Food and Agriculture Organization of the United Nations)/WHO (World Health Organization) Meeting on Pesticide Residues (JMPR). The apple consumption data were taken from the IESTI (international short-term intake) calculation template used by the JMPR. The IESTI was calculated with the currently used method (case 2a) and a proposed one recommended by the EFSA (European Food Safety Authority)/RIVM (Dutch National Institute for Public Health) Scientific Workshop co-sponsored by FAO and WHO. In this example, the ratio of IESTI_proposed/IESTI_current and their combined relative uncertainty are about 2.8, and 1.7, respectively. The larger IESTI and uncertainty obtained with the proposed equation are the consequence of calculation only with the large portion (LP) instead of its combination with unit mass, and the MRL instead of the highest residue (HR). The LP is the major contributor to the combined uncertainty. Both the calculated IESTI and its combined uncertainty depend on the actual food - pesticide residue combination, and should be calculated for each case.

Factors affecting the quantitative uncertainty of the estimated short-term intake. Part II-Practical examples

The effects of the spread of residue concentrations in the samples derived from the selected supervised trials and the number of trials were studied on the magnitude and uncertainty of the short-term dietary intakes calculated with the proposed new procedure (IESTI_p) and that one used currently by the FAO (Food and Agriculture Organization) and WHO (World Health Organization) Joint meeting on Pesticide Residues (JMPR) (IESTI_c). The residue data of 10 pesticides were obtained from supervised trials conducted on apples and pears. The methods described in Part I were used for the calculations of the uncertainty. The results indicate that the ratio of IESTI_P to IESTI_c (φ_IESTI) is directly proportional to the ratio of the estimated maximum residue level (MRL), recommended by the JMPR; to the highest residue (HR) observed in supervised trials, and it may have a wide range depending on the particular conditions. The φ_IESTI becomes greater with the increase of the difference between the mrl or maximum residue limit (MRL, established by the Codex Alimentarius Commission, CAC) and HR, and becomes smaller if the difference between the large portion (LP) and unit mass (U) decreases. The φ_IESTI ranged between 2 and 5.1 in the 16 cases examined indicating that the IESTI_p calculation method leads to higher intake estimates. The ratio of CV_IESTIp and CV_IESTIc ranged typically between 0.62 and 1.71. It rapidly increased up to 12 trials. For a larger number of trials, the ratio remained practically constant (1.69-1.71). The processing factor (PF) equally affects the MRL and HR values, therefore, it will not practically influence the φ_IESTI. The uncertainty of the estimated median residues depends on the spread and number of values in the residue datasets, which affects the uncertainty of the conversion factor (CF) and subsequently the uncertainty of the estimated IESTI_p. Residue values obtained from minimum nine independent trials are required for the correct calculation of the 95% confidence intervals of the calculated median residues. The uncertainty of the analytical results directly affects the median, HR values and indirectly the calculated mrl and the MRL derived from it. Therefore, it should also be considered for the calculation of the combined uncertainty of the conversion factors. For the correct interpretation of the results of dietary exposure calculations, the upper 95% confidence limit of the short-term intake should also be considered. However, it is not the current practice of regulatory agencies or JMPR.

Does EU legislation allow the use of the Benchmark Dose (BMD) approach for risk assessment?

Hazard characterisation is largely based on an approach of (statistically) comparing dose groups with the controls in order to derive points of departure such as no-observed-adverse-effect levels (NOAELs) or lowest-observed-adverse-effect levels (LOAELs). This approach suggests the absence of any relevant effect at the NOAEL. The NOAEL approach has been debated for decades. A recent Scientific Opinion by the European Food Safety Authority (EFSA) concluded that the Benchmark Dose (BMD) approach should be preferred over the NOAEL approach for deriving human (health-based) limit or guidance values. Nonetheless, the BMD approach is used infrequently within European regulatory frameworks. The reason for this may lie in legislation or guidelines requiring the use of the NOAEL approach. In this context, various EU regulatory frameworks were examined on such demands. Interestingly, no single legislation was identified containing statutory requirements in conflict with the use of the BMD approach.

Complex mixtures: relevance of combined exposure to substances at low dose levels

Upon analysis of chemically complex food matrices a forest of peaks is likely to be found. Identification of these peaks and concurrent determination of the toxicological relevance upon exposure is very time consuming, expensive and often requires animal studies. Recently, a safety assessment framework based on the Threshold of Toxicological Concern (TTC) was published to assess the safety of chemically complex matrices more efficiently. In this safety assessment framework, the toxicological relevance of exposure to unidentified substances in chemically complex food matrices can be related to the Cramer class III TTC threshold, currently set at 90 μg/day. However, possible additive or synergistic effects of combined exposure is not covered. The current evaluation describes the relevance of combined low dose exposure to unidentified substances in chemically complex food matrices. It is concluded that to some extent cumulative effects at exposure levels for each substance at or below the Cramer class III TTC threshold, being present in a complex mixture including food, might occur. However the health relevance of possible cumulative effects at this dose level is considered to be that low that a need for a correction factor to cover possible cumulative effects is very low to absent.